Identification of Suppliers of Precious Metals and Gemstones
As part of its due diligence procedures, Imperial-Delta, Inc. has collected information on all suppliers of precious metals and gemstones for the period of January 1, 2025 to December 31, 2025. This entails Know Your Counterparty information that establishes beneficial ownership, banking information, anti-money laundering compliance, and locational information on the suppliers’ operations. Ownership and company information is cross-referenced against objective evidence, such as government-issued identification, public financial filings, business licenses, and other relevant documentation. Imperial-Delta, Inc. also requires its suppliers have a supply chain policy consistent with the OECD Guidance on Supply Chain Due Diligence as a condition of the ongoing business relationship and that any diamond vendors comply with the Kimberly Process Certification Scheme (KCPS), World Diamond Council System of Warranties (WDC SoW), and national law.
Assessment of Suppliers’ Due Diligence Practices
All of Imperial-Delta Inc.’s active suppliers of precious metals and gemstones conform to or exceed Imperial-Delta Inc.’s requirements for KYC information and Supply Chain Due Diligence and transparency. In all cases, KYC information is complete and verified with additional evidence to support the veracity of the information collected. Furthermore, all suppliers of precious metals and gemstones have a Supply Chain Due Diligence policy and procedures in conformance with the OECD, including the requirements of Third-Party audit and Annual Reporting on their ongoing due diligence, which are reviewed by Imperial-Delta Inc.’s Compliance Department alongside its CAHRA identification protocol.
Management Structure and Responsibilities for Supply Chain Due Diligence Risk Identification
Organizational Hierarchy
- Executive Management
- Responsibilities:
- Provide strategic oversight and set risk management goals.
- Approve risk management policies and resource allocation.
- Ensure alignment of due diligence processes with business objectives.
- Works with legal consultants to ensure legality of internal policy and procedures
- Review supplier contracts for clauses that manage risk exposure.
- Compliance Officer
- Responsibilities:
- Oversee the risk identification and mitigation process.
- Review risk reports and escalation procedures.
- Monitor the implementation of corrective actions.
- Ensure integration of due diligence activities across the supply chain.
- Coordinate between departments to ensure comprehensive risk assessment.
- Develop and implement risk mitigation strategies.
- Purchasing Manager
- Responsibilities:
- Collaborate in identifying vendor-related risks
- Perform supplier evaluations and audits.
- Engage in due diligence for new suppliers to assess potential risks.
- Maintains supplier information on the Approved Supplier List
- Operations
- Responsibilities:
- Identify operational risks related to logistics, warehousing, and inventory management.
- Report issues that may affect supply chain continuity and performance.
- IT
- Responsibilities:
- Identify risks related to data security and technology infrastructure.
- Ensure proper risk identification related to third-party systems and cyber threats.
- Risk and Internal Audit Team
- Responsibilities:
- Conduct risk assessments and audits of the supply chain operations.
- Identify gaps in the current due diligence process.
Risks Identified
No risks have been identified for the period of January 1, 2025 to December 31, 2025. This marks Imperial-Delta Inc.’s second year of rigorous engagement with the Due Diligence program outlined in this report, and it will continue to review and assess its own due diligence practices for continued improvement.
Strategy to Respond to Identified Risks
As there are no identified risks based on KYC, AML, and CAHRA Identification protocols for this period, this section is not applicable, but will be included in subsequent Annual Reports as necessary based on any identified risks for that period.
Supply Chain Policy
Purpose and Scope
This Supply Chain Policy outlines The Bazar Group Inc. (Imperial-Deltah & Imperial LGD Divisions) commitment to responsible sourcing and ethical supply chain management. It applies to all suppliers, contractors, and business partners involved in the procurement, handling, processing, trade, and sale of materials—including both natural and laboratory-grown materials—across our supply chain.
Commitment to Responsible Business Practices
The Bazar Group Inc. (Imperial-Deltah & Imperial LGD Divisions) is committed to conducting business in a legally compliant, ethical, transparent, and socially responsible manner throughout our supply chain. We recognize that responsible supply chain practices build trust with stakeholders, enhance sustainability, and reduce environmental, social, and governance (ESG) risks.
Legal Compliance
The Bazar Group Inc. (Imperial-Deltah & Imperial LGD Divisions) will:
• Comply with applicable national and international laws and regulations, including those related to labor, environment, anti-corruption, and trade controls.
• Maintain awareness and systems to ensure ongoing compliance, including updated regulatory requirements relevant to our industry and supply chain.
Human Rights and Labor Standards
The Bazar Group Inc. (Imperial-Deltah & Imperial LGD Divisions) supports internationally recognized human rights and labor standards. We expect all suppliers and partners to:
• Respect the rights of workers, including freedom of association and collective bargaining, fair wages, and safe working conditions.
• Prohibit forced, bonded, compulsory or child labor in any form.
• Uphold nondiscrimination and equality in employment practices.
• Provide a safe and healthy working environment for all workers.
5. Supply Chain Due Diligence
We will implement and maintain a robust due diligence process to identify, assess, prevent, mitigate, and account for actual or potential adverse impacts associated with our supply chain, in alignment with strong due diligence frameworks (e.g., OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas). This includes:
• Risk identification and mapping of suppliers, materials, and sourcing regions for human rights, labor, environmental, and governance risks.
• Collection of relevant documentation on material origin and supplier practices.
• Regular risk reviews and updates as part of ongoing supplier assessment.
• Escalation and corrective action when risks are identified.
• Suspension or termination of supplier relationships where mitigation is not feasible.
6. Supplier Expectations and Management
We require suppliers to:
• Adhere to this policy and demonstrate ethical and responsible practices.
• Provide transparency on material origin (including chain-of-custody information for materials where applicable).
• Implement their own responsible supply chain practices and due diligence.
• Cooperate in audits, information requests, and corrective action plans.
7. Environmental Stewardship
The Bazar Group Inc. (Imperial-Deltah & Imperial LGD Divisions) and its suppliers must commit to environmentally responsible practices, including:
• Efficient use of natural resources and minimizing environmental impact (e.g., energy, water, emissions).
• Compliance with all applicable environmental laws and regulations.
• Prevention and mitigation of pollution and environmental degradation.
8. Anti-Corruption and Ethical Behavior
We have zero tolerance for bribery, corruption, fraud, or unethical behavior. Our suppliers and partners must conduct business with integrity and adherence to anti-corruption laws and ethical standards.
9. Grievance Mechanisms and Reporting
We maintain mechanisms for workers, suppliers, and stakeholders to raise concerns regarding violations of this policy, including confidentiality and non-retaliation protections. Feedback and grievances will be reviewed and acted upon in a timely and transparent manner.
10. Monitoring, Audit, and Continuous Improvement
The Bazar Group Inc. (Imperial-Deltah & Imperial LGD Divisions) will regularly monitor supplier performance to this policy through:
• Internal assessments and documented due diligence activities.
• Third-party audits where required.
• Performance metrics and corrective actions.
• Ongoing training and capacity building for staff and suppliers.
11. Communication and Transparency
This policy is communicated internally to Senior Management It will be publicly available to vendors and customers and reviewed periodically to ensure continued relevance and effectiveness.
12. Policy Review
This policy will be reviewed at least annually and updated in response to regulatory changes, stakeholder feedback, and evolving best practices in responsible supply chain management.
Signed/endorsed:
Jonathan Louttit
Chief Operating Officer